In re Marriage of Layer, 2022 IL App (3d) 210304-U

1. Case citation and parties
- In re Marriage of Layer, 2022 IL App (3d) 210304‑U (Apr. 28, 2022) (Rule 23 order; non‑precedential except as allowed by Rule 23(e)(1)).
- Petitioner‑Appellee: Amy M. Layer. Respondent‑Appellant: Benjamin M. Layer.

2. Key legal issues
- Whether the trial court’s allocation of parenting time was against the manifest weight of the evidence.
- Application of the “best interests of the child” factors in 750 ILCS 5/602.7(a) and deference to the trial court’s credibility and factual findings.

3. Holding/outcome
- Affirmed. The appellate court held the trial court’s parenting‑time allocation was not against the manifest weight of the evidence. The court essentially adopted the parties’ 2019 mediated parenting plan, giving Amy somewhat greater parenting time as the primary caregiver.

4. Significant legal reasoning
- Standard of review: parenting‑time allocations receive great deference because the trial court assesses credibility and local facts; reversal only if result is against the manifest weight of the evidence or an abuse of discretion.
- The court applied the statutory 602.7 best‑interest factors, noting no single factor strongly favored either parent. Two factors—(a) time each parent performed caretaking in the 24 months before filing, and (b) any prior agreement/course of conduct—tilted slightly toward Amy.
- The mediation plan had been in place since June 2019, and the children (ages 8 and 11 at hearing) were thriving, well‑adjusted, and had stable routines and school placements. Both parents were fit, involved, and able to promote the other’s relationship with the children.
- Given the balance of factors and the established, functioning parenting schedule, preserving stability and continuity supported the trial court’s decision to continue substantial, though not equal, parenting time for both parents.

5. Practice implications
- Mediated parenting plans and established post‑separation custody routines carry substantial weight; courts favor continuity when children are well‑adjusted under an existing plan.
- When statutory best‑interest factors are largely balanced, trial courts are likely to preserve the status quo—attorneys should document caretaking contributions and course of conduct (who provided routine care, drop‑offs, school transport, extracurricular involvement).
- To succeed on appeal, counsel must show the trial court’s decision was clearly unreasonable or unsupported by evidence; factual findings and credibility calls are difficult to overturn.
- Practical tips: develop a clear record on 602.7 factors (adjustment, parental fitness, willingness to facilitate access, work schedules, distance), and emphasize any deleterious effects of disrupting established routines if seeking a change.